bitexbit AML / KYC / CTF Policy

Last amended: January 1, 2024

Please read carefully this Anti-Money Laundering / Know Your Customer Policy (hereinafter the “AML/KYC Policy”, “Policy”) before using a website at https://bitexbit.com or any our Services.

This Policy is designated to prevent and mitigate possible risks of Bitexbit being involved in any kind of illegal activity, such as money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery. Policy complies with applicable legal regulations and will be reviewed, updated on a regular basis to ensure appropriate policies, procedures and internal controls.

AML/KYC/CTF Policy covers the following matters:

  • Internal controls;

  • Identification and Verification procedures;

  • Sanction policy and PEP lists screening;

  • AML Compliance Officer;

  • The User’s Remote Identification (Legal Entities)

  • Monitoring Transactions;

  • Risk Assessment;

  • Business Relationship Monitoring;

  • Reporting obligations.

  1. INTERNAL CONTROLS

    As an integral part of our commitment to regulatory compliance and risk management, we have developed and are following the deliberate Anti Money Laundering (“AML”) and Counter-Terrorist Financing (“CFT”) Policies. This Policies serve as a foundational framework for our operations, outlining the procedures and protocols we follow to ensure compliance with AML/CFT regulations.

    Some of those internal controls are listed within this document and include, but are not limited to, the User identification / verification, the suspicious activity monitoring and reporting.

    Bitexbit reserves the right to collect User’s identification information for the AML/CFT Policy purposes. Users may be identified using a variety of methods including but not limited to:

    • Require the verification of User's phone number;

    • Require submission of User’s identification documents, such as a passport or driver's license with a photograph;

    • Require for the User to conduct a liveness check;

    • Cross-check the names of Users against compliance databases such as the OFAC Specially Designated Nationals list and other governmental watch lists;

    Identification.Our identity verification procedure requires the User to provide with reliable, independent source documents, data or information (for example, national ID, international passport, bank statement, utility bill). Such documents shall be sent in high-quality color format. Bitexbit reserves the right to reject any documents, which do not comply with the above.

    Bitexbit requires such documents, data or information to enable the User identification; verify the identity of each User; record User’s identification information and the verification results; and compare User identification information with government-provided lists of suspected terrorists, once the government has issued such lists. For such purposes Bitexbit reserves the right to collect User’s identification information.

    Verification. Bitexbit will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Bitexbit reserves the right to investigate certain Users who have been determined to be risky or suspicious. In addition, Bitexbit reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). Bitexbit also reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.

    Enhanced KYC procedures. Bitexbit may entail the solicitation of proof of source of funds and/or proof of wealth from Users. Data collection and verification from Users are primarily facilitated through our third-party KYC provider SumSub. However, in certain instances, data may undergo manual querying, processing, and verification by a Bitexbit’s Monitoring Specialist.

    Privacy. Privacy. Bitexbit reserves the right to keep all the identification information provided by the User, verification results and any discrepancies identified in the verification process. This information will be collected, stored, shared and protected strictly in accordance with the Bitexbit Privacy Policy and related regulations.

  2. SANCTION POLICY AND PEP LISTS SCREENING

    Bitexbit may refuse from transactions with any person identified as a “Specially Designated National”, United States citizen or permanent resident of the United States, nor has a primary residence or domicile in the United States, including Puerto Rico, the U.S. Virgin Islands, and any other possessions of the United States. Bitexbit may also refuse from transacting with citizens and residents of unrecognized territories and/or states as well as temporarily occupied territories of Ukraine as a result of russian aggression.

    Bitexbit may refuse from transactions with individuals, companies and countries that are on prescribed Sanctions lists. Bitexbit will therefore screen against United Nations, European Union, UK Treasury and US Office of Foreign Assets Control (OFAC) sanctions lists in all jurisdictions in which we operate. Bitexbit also screens Users against recognized Sanctions and Politically Exposed Persons (PEPs) lists. Individuals and legal entities are screened against mentioned lists: (i) on the onboarding stage when the user is submitting the application; and (ii) on each anti-fraud and AML alerts manually by Compliance Officer.

  3. AML COMPLIANCE OFFICER

    The AML Compliance Officer is the person, duly authorized by Bitexbit, and fully responsible for implementing and enforcing AML/CFT program. The duties of the AML Compliance Officer with respect to this Policy shall include, but are not limited to:

    • Collecting Users’ identification information;

    • Establishing and updating internal AML/CFT policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;

    • Maintaining necessary and appropriate records;

    • Monitoring transactions and determining any suspicious activity;

    • Ensuring independent audits of the AML/KYC policy;

    • Providing law enforcement with information as required under the applicable laws and regulations;

    • Ensuring that the AML/CFT policy, procedures, and internal control measures are adequate and proportionate;

    The AML Compliance Officer is entitled to interact with law enforcement authority, which is involved in prevention of money laundering, terrorist financing and other illegal activity.

  4. THE USER'S REMOTE IDENTIFICATION (LEGAL ENTITIES)

    For legal entity Users, Bitexbit has established a standardized KYC protocol. Verification of USer legal entity data is conducted by a designated Onboarding Specialist. The User's appointed representative is obligated to undergo the requisite Know Your Customer procedure and furnish the following information:

    • confirmation of a contact phone number;

    • submission of an identity document;

    • completion of a liveness check;

    • provision of documentation validating the representative's authority to act on behalf of the legal entity.;

    Upon successful completion of the KYC process, a questionnaire is dispatched to the User's representative. The questionnaire is completed using the platform of our KYC provider, SumSub, wherein the User's representative must affirm:

    • understanding, acknowledgment, and agreement with the Terms of Use, Privacy Policy, and the present AML Policy;

    • confirmation that neither the User’s representative, nor any beneficial owners, shareholders, senior management, or directors are Politically Exposed Persons or close associates thereof.

    The User's representative is required to provide:

    • responses to the questionnaire;

    • extract of registry card or registration certificate of the relevant register, or an equivalent document;

    • list of beneficiaries or equivalent documents (e.g., extended registry card);

    • proof of address and identification documents for all shareholders and beneficial owners of the User;

    • documents substantiating the User’s proof of address;

    • documents validating the Source of Wealth and Source of Funds.

  5. SUSPICIOUS ACTIVITY MONITORING AND REPORTING

    The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Bitexbit may monitor transactions to detect the suspicious activity.

    For the purposes of this Policy suspicious activity may be defined as the transaction which (1) involves funds derived from illegal activity or is intended or conducted to hide or disguise funds or assets derived from illegal activity; (2) is designed, whether through structuring or otherwise, to avoid any recordkeeping or reporting requirements of the regulations; (3) has no business or apparent lawful purpose; or (4) facilitates criminal activity, including the use of Bitexbit in such actions.

    Transactions that are unusual will be carefully reviewed to determine if it appears that they make no apparent sense or appear to be for an unlawful purpose. Bitexbit reserves the right to request the User to provide any additional information and documents in case of suspicious transactions; and suspend or terminate User’s Account when Bitexbit has reasonably suspicion that such User engaged in illegal activity.

    The Compliance Officer shall file a report, including supporting documentation, to notify the appropriate authority in situations involving violations requiring immediate attention, such as terrorist financing, continued money laundering schemes or other financial crime. And Bitexbit reserves the right to file a voluntary report for any suspicious transaction that we determined as a potential violation of any law or regulation.

  6. BUSINESS RELATIONSHIP MONITORING

    Business Relationship Monitoring is a fundamental aspect of Bitexbit’s AML/CFT policies aimed at continuously assessing and scrutinizing the activities of our business relationships with Users. This proactive approach enables us to identify and mitigate risks associated with financial crimes such as money laundering, terrorist financing, and fraud. By closely monitoring the transactions, behaviors, and patterns of our Users, we can promptly detect any suspicious activities and take appropriate measures to ensure compliance with regulatory standards and uphold the integrity of our operations

  7. RISK ASSESSMENT

    Pursuant to the international requirements the Bitexbit has adopted a risk-based approach towards assessing and managing the money laundering and terrorist financing risks. Therefore, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. The principle is that resources should be directed accordingly to priorities so that the greatest risks receive the highest attention.